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In addition to the proposed Keystone XL, the Keystone Mapping Project (KMP) now includes the Keystone Pipeline route map through North Dakota, South Dakota, and Nebraska.

Initially, the KMP had only mapped the proposed Keystone XL, whose southern segment was called the Gulf Coast Extension. As originally envisioned, the Keystone XL route ran through Montana, South Dakota, Nebraska, Oklahoma, and Texas. While only the Oklahoma-Texas Gulf Coast Extension of the Keystone XL was built, its construction in 2014 allowed for the Keystone complex of pipelines to extend north-south across the United States. The Keystone’s northern segment was completed in 2010 and ran from the Canadian border, through North Dakota, South Dakota, and Nebraska. The following year it was connected to the the tank farm in Cushing, Oklahoma via the Kansas Keystone-Cushing Extension. From there, the Gulf Coast Extension completed the Canadian oil’s route to Gulf Coast refineries.

As the KMP published the Cushing-Extension Pipeline route last year, the addition of the Keystone ND, SD, and NE routes now completes the north-south mapping of the larger Keystone Pipeline complex. These new maps show both Keystone XL and Keystone entry points at the Canadian border and follow the two routes to the Gulf Coast.

With the release of the Final Supplemental Environmental Impact Statement (FSEIS) by the Department of State (DoS) on January 31, 2014, one would think more clarity would have been brought to the Keystone XL route and the pipeline’s impacts. In January of 2013, I was told by the DoS that the agency had milepost data to 1/10th of a mile and that updated maps and waterbody tables would be included in an upcoming report. Now a year later, the report has just been released and, not only is the milepost data still missing, but updated route maps have been redacted “as sensitive information not for public distribution.” (Appendix B,C,&D). The Environmental Report’s author, Exponent, does not seem to be aware that both PHMSA and FERC consider pipeline data public and that the pipeline route will be easily located once construction begins. Upon completion, marker stakes will caution construction crews to the buried pipeline. The route maps from the 2008 FEIS and 2009 SEIS, sans latitude/longitude data, remain online.

Montana’s Department of Environmental Quality (MDEQ), South Dakota’s Department of Environment and Natural Resources (SD DENR), and the South Dakota Public Utility Commission (SD PUC) all claim that they do not have the most current route data. TransCanada will submit route data to these agencies after the White House approves the project and forty-five days before construction begins. Evidently, at that point the data ceases to be “sensitive.”

According the South Dakota Keystone Public Liaison officer – an appointee of the the SD PUC who is paid by TransCanada to deal with landowner issues, since 2009 many groups have been visiting South Dakota to survey the route, including Native American tribes, biologists, archaeologists, and engineers, related and unrelated to TransCanada. This indicates a much broader interest in the route. So why aren’t state and Federal agencies making this GIS data publicly available?

Now, courtesy of a Freedom of Information Act (FOIA) request, the US Fish and Wildlife Service has filled in in many of the gaps by releasing the August 2012 centerline map of the Keystone XL. For the Montana section this newly released route falls within the MDEQ’s currently publicized 500 foot corridor. The Nebraska segment is identical to the revised centerline route released in the May 1, 2013 SEIS. In contrast, the South Dakota route shows nearly 30 changes. Route changes can be cross referenced to tables on the DSEIS (8 MB) and FSEIS (8 MB).

I have found the report lacking in supporting data. The report frequently references the Department of State’s FEIS and Transcanada, neither of which provide sufficient data to make a proper evaluation of the project.

After careful review, I have found the NDEQ’s October 2012 Draft Evaluation Report for the proposed Keystone XL project (Report) lacking in key data and detail that preclude a proper evaluation of the Keystone XL’s environmental impacts. Of greatest concern are the insufficiency of both the GIS routing data and spill mitigation details in the report.

Inadequate Data and Over-Reliance on DOS FEIS

The NDEQ’s report relies too heavily on the Department of State’s Final Environmental Impact Statement (FEIS) in making its analysis and supporting its assertions. Conspicuously missing from the FEIS are the location data for the pipeline’s key landmarks, including milepost (MP) markers and waterbody crossings. Despite their absence, the MP markers are repeatedly referenced throughout both the project and DOS documents and are critical for all discussions of the pipeline route, potential environmental impacts, and surrounding points of interest. The GIS data released by the NDEQ is inadequate, as well, for the following reasons:

Milepost Markers: The NDEQ report furnishes MP markers for even miles only, whereas the FEIS requires accuracy to the nearest tenth of a mile.

Waterbody Crossings: The NDEQ acknowledges that the Nebraska Keystone route has 163 waterbody crossings, but the NDEQ’s digital map file only contains the five largest.

Gas & Water Wells: The gas and water well data contained in the FEIS has not been updated to reflect the revised Nebraska route.

While all parties, including PHMSA, FERC, and all state agencies, acknowledge that the pipeline’s GIS data is public information, neither the DOS nor TransCanada will release this information. The hardcopy maps in the FEIS do not contain longitude and latitude information. TransCanada’s manager of Stakeholder Relations, Terry Cunha, has gone so far as to claim that the Keystone XL route location data is a matter of national security. If this is true, this danger has not been conveyed to the public nor acknowledged in the subject Report. The Report and the FEIS on which it relies cannot be considered suitable for public review until a complete open-source digital dataset has been made readily available at no cost.

Inadequate Spill Mitigation

Neither the FEIS nor the NDEQ’s report sufficiently addresses TransCanada’s preparation for spill prevention and mitigation. It is alarming that TransCanada has yet to develop an Emergency Response Plan for the Keystone XL. A non-profit group, Plains Justice, brought these deficiencies to public attention over two years ago in their report, The Northern Great Plains at Risk: Oil Spill Planning Deficiencies in Keystone Pipeline System (http://tinyurl.com/cwzffo9). Given the experience of a recent pipeline spill in Kalamazoo, Michigan, where cleanup costs are $1 billion and climbing, TransCanada’s $200 million third party liability insurance is grossly inadequate. Permitting should also be subject to EPA review. It would be negligent to repeat the Gulf Coast approval process, whereby USACE gave sweeping project-wide construction approval to TransCanada through a Nationwide Permit 12 and withheld waterbody crossing data until after granting their approval.

It is disturbing that TransCanada has not been required to fully disclose details of the pipeline route to the public or to document adequate emergency spill response measures. The public review process requires more accurate and complete information than have been provided to date by TransCanada, the DOS, and the NDEQ.

The first installment of the eminent domain map is now online. We have begun with the state of Texas and will add more eminent domain data as it becomes available. If you would like to contribute data to this map:

The county data for Texas comes courtesy of State Impact Texas. Statewide there were 102 eminent domain filings by TransCanada. Landowners typically fall into one of three categories:

Those who have willingly signed a lease with TransCanada

Those who have begrudgingly signed so as to avoid legal action, and

Those who have been forced to give right away to TransCanada due to eminent domain proceedings.

To ease web viewing, the Keystone Mapping Project’s Google Map data has been consolidated into a single map. The Keystone XL – 2D Complete map contains available data for milepost markers, waterbody crossings, gas and water wells, and eminent domain filings. The map will be updated and expanded as more data becomes available, giving viewers a single resource for a cursory view of the Keystone XL pipeline. For now, the individual maps are also being maintained.

For those seeking more detail, the KMP Google Earth view remains the most comprehensive map of the Keystone XL.

The Keystone Mapping Project was featured on NPR’s StateImpact in Texas with an interview of KMP creator Thomas Bachand. In the interview, Bachand discusses his motivations for building the KMP and the widespread support the project has received. Click here to read Terrence Henry’s Q & A with Thomas Bachand.

Jeff Cohn in Southern California has put together a great crowd-sourcing web site for locating oil and gas drilling sites and associated health and safety issues. An interesting interactive feature allows users to directly add location points and associated health and safety information to the map.